OPINION
NIMS, Chief Judge:
This case is before the Court on petitioners' motion to restrain the collection of taxes and respondent's motion to dismiss for lack of jurisdiction as to petitioner Gabriel Schlosser.
By statutory notice dated October 11, 1989 (deficiency notice), respondent determined deficiencies in and additions to petitioners' Federal income taxes for the years 1983, 1984, and 1985 as follows:
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